Edwards-Moss & anr v HMRC [2016] UKFTT 147 (TC)
July/August 2016 #161This appeal concerned the estate of Lady Edwards-Moss (the deceased) who died on 8 February 2007. The executors of her estate appealed against a determination under s221 IHTA 1984. HMRC argued that the liability arose on two alternative bases. First, the transfer of a freehold farm in return for an annuity on 23 January 2007 (very shortly before her death) was ineffective (either on the basis that it was legally ineffective or under the reservation of benefit rules). Alternatively, this was a transfer at an undervalue, and therefore a transfer of value on which an IHT liability ...